ML11273A175

Joint Motion to Amend the Initial Scheduling Order

ML11273A175
Person / Time
Site:	Seabrook
Issue date:	09/30/2011
From:	Hamrick S, Ross M NextEra Energy Seabrook
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 21161, 50-443-LR, ASLBP 10-906-02-LR-BD01
Download: ML11273A175 (4)

Text

September 30, 2011 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

NextEra Energy Seabrook, LLC ) Docket No. 50-443-LR

)

(Seabrook Station) )

) ASLBP No. 10-906-02-LR (Operating License Renewal) )

Joint Motion to Amend the Initial Scheduling Order NextEra Energy Seabrook, LLC (hereinafter NextEra), on behalf of itself and the NRC Staff, Intervenors Beyond Nuclear, Sierra Club of New Hampshire, and Seacoast Anti-Pollution League, and Intervenors Friends of the Coast and the New England Coalition, hereby moves the Atomic Safety and Licensing Board (Board) to further amend its April 4, 2011 Initial Scheduling Order to modify its deadline for submitting a proposed protective order and nondisclosure agreement.

The Board recently granted NextEras motion to modify the Initial Scheduling Order, moving the deadline for production of mandatory disclosures from October 3, 2011 to April 2, 2012. Order (Granting Motion to Modify Deadline for Initial Disclosures) (Aug. 23, 2011). At that time, no change was made to Paragraph B of the Initial Scheduling Order, which requires the parties to submit a proposed protective order, also by October 3, 2011.

In accordance with the Boards Initial Scheduling Order, the parties have conferred for the purpose of developing a proposed protective order and nondisclosure

agreement concerning the handling of documents that are proprietary or otherwise sensitive, but have not yet reached an agreement to submit to the Board. The parties have also engaged in discussions regarding other aspects of discovery management. The parties would prefer to reach agreement among themselves and believe that they can resolve these issues by November 10, if not sooner. In light of these ongoing discussions and of the Boards earlier amendment of the Initial Scheduling Order to no longer require mandatory disclosures on October 3, the parties jointly request the Board to amend Paragraph B of its Initial Scheduling Order to require the submittal of a proposed protective order by November 10, 2011.

Respectfully Submitted,

/Signed electronically by Steven Hamrick/

Mitchell S. Ross Steven Hamrick NextEra Energy Seabrook, LLC NextEra Energy Seabrook, LLC 700 Universe Blvd. 801 Pennsylvania Avenue, N.W. Suite 220 Juno Beach, Florida 33408 Washington, DC 20004 Telephone: 561-691-7126 Telephone: 202-349-3496 Facsimile: 561-691-7135 Facsimile: 202-347-7076 E-mail: mitch.ross@fpl.com E-mail: steven.hamrick@fpl.com Counsel for NextEra Energy Seabrook, LLC 2

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

NextEra Energy Seabrook, LLC ) Docket No. 50-443-LR

)

(Seabrook Station) )

) ASLBP No. 10-906-02-LR (Operating License Renewal) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Joint Motion to Amend the Initial Scheduling Order, were provided to the Electronic Information Exchange for service to those individuals listed below and others on the service list in this proceeding, this 30th day of September, 2011.

Administrative Judge Administrative Judge Paul S. Ryerson, Esq., Chair Dr. Michael Kennedy Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Email: psr1@nrc.gov Email: michael.kennedy@nrc.gov Administrative Judge Secretary Dr. Richard E. Wardwell Attn: Rulemakings and Adjudications Staff Atomic Safety and Licensing Board Mail Stop O-16 C1 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 hearingdocket@nrc.gov Email: richard.wardwell@nrc.gov

Office of Commission Appellate Adjudication Mary Spencer, Esq.

Mail Stop O-16 C1 Maxwell C. Smith, Esq.

U.S. Nuclear Regulatory Commission Richard Harper, Esq.

Washington, DC 20555-0001 Office of the General Counsel E-mail: OCAAMAIL@nrc.gov Mail Stop O-15 D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: mary.spencer@nrc.gov Raymond Shadis Kurt Ehrenberg New England Coalition New Hampshire Sierra Club Post Office Box 98 40 N. Main Street Edgecomb, Maine 04556 Concord, NH 03301 E-mail: shadis@prexar.com E-mail: Kurt.Ehrenberg@sierraclub.org Paul Gunter, Reactor Oversight Project Doug Bogen Beyond Nuclear Executive Director 6930 Carroll Avenue, Suite 400 Seacoast Anti-Pollution League Takoma Park, MD 20912 PO Box 1136 E-mail: paul@beyondnuclear.org Portsmouth, NH 03802 E-mail: bogen@metrocast.net Matthew Brock Assistant Attorney General Environmental Protection Division Office of the Attorney General One Ashburton Place, 18th Floor Boston, Massachusetts 02108 matthew.brock@state.ma.us

/Signed electronically by Steven Hamrick/

Steven Hamrick 2